Legislation and Market Forces: PKI Drivers for the U. S. Mortgage Industry November 27, 2006 R. J. Schlecht Director, Industry Technology – Security &

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Presentation transcript:

Legislation and Market Forces: PKI Drivers for the U. S. Mortgage Industry November 27, 2006 R. J. Schlecht Director, Industry Technology – Security & Compliance

Secure Identity Services Accreditation Corporation SISAC Develops baseline standards for auditing and accreditation of certificate/credential issuers »SISAC does not issue credentials, rather accredits Service Providers, e.g., VeriSign, GeoTrust, Mortgage entities, etc. Technical, Business and Legal requirements B2B model for authentication Wholly-owned subsidiary of MBA

SISAC - Requirements Standards developed by SISAC Advisory Group »Fannie Mae, Freddie Mac and mortgage participants »Advisory group is open to other entities »Standards drafted by Relying Parties Aligned with PKI best practices »Federal Bridge (FBCA), OMB 0404, NIST, etc. Business contract infrastructure »RA, Subscriber, Relying Party agreements »Defined obligations for all participants Liability requirements »Credential Issuer Liable for Errors & Omission (E&O) Not fraud or transaction »Basic ($1M), Medium ($5M), High ($10M)

eDoc Prep Service Ordering: Credit Flood Hazard Title MI MERS® eRegistry (National eNote Registry) eVault eDocuments eNote Data, Messaging & Control eOrigination & Underwriting External Docs eRecording Legal eDocs (Land records, tax liens, other docs/affidavits ) eClosing BuyerSeller eNotarization eSignatures eMortgage Process Flow Secondary Investor, Aggregator eVault Servicing

SISAC – Flexibility Three levels of Assurance »Basic, Medium & High Accreditation models »Full and outsourced providers »Independent or corporate providers Types of Subscriber Certificates »User certificates Individual or Organizational »Device certificates Ability for Replying Parties to add requirements

Legislation Uniform Electronic Transactions Act (UETA) Electronic Signatures in Global and National Commerce Act (E-SIGN) Gramm-Leach-Bliley Act Regulations »Federal Financial Institution Examination Council (FFIEC) »Federal Trade Commission (FTC) U. S. States »California Senate Bill 1386 (Security Breach) »Over 30 other States

MERS – National eNote Registry Designation of authoritative Promissory eNote Single source for Mortgage Industry of electronic Note »Notes are traded between primary, warehouse, secondary. Launch production »April 26, 2004 MERS Requirements »Tamper-evidence seal on envelope SISAC Organizational Medium Assurance Cert »Individual Identity on specific Transactions SISAC Individual Medium Assurance Cert

eNote Registry

National Notary Association (NNA) eNotarizaiton of electronic records State and County Recorders/Requirements Strong authentication, with validation and revocation Document integrity Potential fraudulent exploitation of notaries Non-proprietary model

Lessons Learned Business infrastructure and liability Relying parties are interested in complying with legislative and business requirements; not credential services Legislation legalized electronic signatures and documents, and security controls for protecting personal information Relying parties bear the risk and therefore should have a critical role in defining policy requirements Ability to leverage existing CPs/CPSs and audit practices Emergence of early industry adopters; eRegistry and eNotarization services Flexible model without compromise of standards

Addressing the PKI Adoption Issues Poor or missing support for PKI in software applications; High adoption costs; Poor understanding of PKI among senior managers and end-users; Too much focus on technology and not enough on business needs; and, Interoperability problems.

Contact R. J. Schlecht Director, Industry Technology Security & Compliance Mortgage Bankers Association Washington, DC